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Respondent determined deficiencies in petitioner's Federal
income taxes and additions to tax for the years indicated:
Addition to Tax
Year Deficiency Sec. 6651(a)(1)
1990 $739 $101
1991 949 100
1992 1,174 118
1993 1,391 114
The issues for decision are: (1) Whether petitioner
received and failed to report income for the taxable years in
issue; and (2) whether petitioner is liable for the section
6651(a)(1) additions to tax for the taxable years in issue.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner resided in Indianola,
Mississippi, on the date the petition was filed in this case.
Petitioner worked for Gresham Service Stations, Inc. (GSS)
in Indianola during 1990, 1991, and 1992. He also worked for
Double Quick, Inc. (DQ) in Indianola during 1992 and 1993. The
corporations reported on Forms W-2 and later verified in letters
to respondent that petitioner earned wages in the following
amounts during the taxable years in issue:
Year GSS DQ
1990 $ 9,684 -
1991 11,344 -
1992 5,062 $ 8,075
1993 - 14,748
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Last modified: May 25, 2011